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Privacy Notice

This privacy notice explains in clear language, how Martyn Carr Coaching uses the personal information we collect from Data Subjects, either through using our website, or in any other way, electronically, verbally or in writing. 

Topics:

  • Data Controller
  • Basis for collecting your data (lawful processing)
  • Recipients of data and data transfers
  • Sensitive information
  • Categories and type of Personal Data collected
  • Retention Policy
  • Your rights as a data subject
  • Automated decision making

Data controller

Martyn Carr Coaching LTD is the Data Controller. We can be contacted at hello@martyncarrcoaching.co.uk or telephone number +44 (0)7740 638414.

On what basis do we collect and process your data? (known as lawful processing)

Data Privacy law defines the basis by which we can lawfully collect and process personal data. For the data where we act as Data Controller, we have determined the following:

To enter into or in pursuance of a Contract:

We will collect personal data when engaging with individuals to enter into a contract, such as a service contract. We will continue to process that data for the duration and subsequently after the contract expires or is terminated.

In our legitimate interest:

We will collect and process personal data where it is in the legitimate interest of Martyn Carr Coaching LTD to do so. Specifically, we use legitimate interest in relation to our clients and in order to identify prospective clients and if engaged, we continue to process personal data to manage our commercial relationship. This will include but is not limited to the continued processing (retention) of records of our transactions and interactions. An Interest Assessment has been conducted to ensure that the legitimate interests of the organisation does not outweigh that of the data subject. The data collected will not be used for any unlawful or unethical purpose.

Data recipients and data transfers

We do not sell any of your personal data to any third parties. Where required, Martyn Carr Coaching LTD will share personal data with service providers such as accountants. We may share your personal information with printing and mailing companies, as well as email service providers and other delivery companies.

Where required we will disclose your personal data with law enforcement and fraud prevention agencies. This is so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject. Additionally, we will disclose your personal data in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Data is transferred by our email host and held in UK based accredited data centres. Personal data is also contained within our proprietary Apple applications and backed up to the Apple cloud. This cloud solution is located in the USA and is subject to the Privacy Shield framework. This framework has been subject of an adequacy decision by the European Data Protection Board. Our accounting software stores data in the USA.

Sensitive information

Martyn Carr Coaching LTD does not process sensitive data as defined by Article 9 of the GDPR.

Categories and types of data

We process the following data of our Enquirers:

  • Name
  • Phone number
  • Email address
  • Details of enquiry

We process the following personal data of our Contracting clients:

  • Name
  • Address
  • Phone number
  • Email address
  • Signature

We process the following personal data of those we Coach:

  • Name
  • Phone number
  • Email address
  • Next of kin name and contact details
  • Coaching outcomes
  • Context of coaching
  • Coaching goals
  • Coaching notes
  • Reports to contracting client

We collect data in relation to your communications and interactions with us. This can include emails, text messaging, postal service delivery, social media posting or any other form of communication. In addition to the lawful purpose described previously for the above categories, we have a legitimate interest purpose to collect and retain this data to enable and improve our communication and for record keeping purposes.

The data we collect as data controllers from our data subjects is obtained directly from the data subject themselves or is obtained from sources such as the contracting client or social media platforms. Please see our Cookie Policy for information on the data collected by our website.

Retention Policy

The data we collect directly from you is the minimum we require to facilitate the lawful processing described above. Martyn Carr Coaching LTD has developed a retention policy to ensure personal data is held only for as long as is required for the purpose we collected it and for our legitimate purposes.

Generally, we will retain personal data of Enquirers for 1 year should that enquiry not result in a commercial engagement.

Personal data of our contracting clients will be held for the duration of any commercial agreement between us and further for marketing purposes providing the appropriate consent or legitimate interest purpose is in place.

Personal data processed for those we coach will be held for the duration of the coaching agreement and for 5 years thereafter. This is in order to provide us with management information and to allow for any request for information from the coachee.

Personal data may be retained for other periods if required by legal obligation, such as HMRC requirements.

Data Storage and Security

Martyn Carr Coaching LTD follows strict security procedures to ensure that your personal information is not damaged, destroyed, or disclosed to a third party without your permission and to prevent unauthorised access. We store data within our own physical IT network. Our data is subject to rigorous back up regimes to prevent data loss and continuance of service.

The computers storing the information are kept in a secure environment with restricted physical access. We use secure firewalls and other measures to restrict electronic access, including Apple anti-virus and anti-malware measures. If the data must be transferred to a third party, we require them to have in place similar measures to protect your personal data.

The information we collect and process as data controllers is restricted to our offices. Only persons who need the information to fulfil their duties are granted access to personal data. We may require you to cooperate with our security checks before we disclose information to you. You can update the personal information that you give us at any time by contacting us directly.

Cookies from our website

To make our website work properly, we place small data files called cookies on your device.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. They can also provide analytical data about your usage of our website.

How do we use cookies?

A number of our pages use cookies to remember:

  • Your display preferences, such as contrast colour settings or font size
  • If you have already replied to a survey pop-up that asks you if the content was helpful or not (so you won’t be asked again)
  • If you have agreed (or not) to our use of cookies on this site
  • Analytical purposes

The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

How to control cookies

You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org  You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

Cookies we use are:

_gid Performance Google Analytics used to store and update a unique value for each page visited.
_ga Performance Used to calculate visitor, session and campaign data for the site’s analytics reports.

Your rights as a data subject

The regulations provide a number of rights to you as the Data Subject. Martyn Carr Coaching LTD is committed to upholding those rights and those applicable to the personal information we collect and process are listed below. In addition to these rights, you have the right to escalate any concern to the Supervisory Authority, which in the UK is the Information Commissioners Office https://ico.org.uk.  A full and detailed explanation of all rights can be found at https://ico.org.uk/for-the-public/

  • The Right to be Informed – you should be clear about what, why and in what way your personal information will be processed at the time it is processed. This privacy policy sets out that information.
  • Right of Access – you have the right to know what personal information is held, by whom and why.
  • The Right to Rectification – If the information we have collected and processed is inaccurate or incomplete, you have the right to have it rectified.
  • Right to Erasure – You have the right to have your personal data erased and to prevent processing in some specific situations.
  • Right to Restrict Processing – If you contest the accuracy of the personal data we hold, we will restrict the processing of your data until accuracy is verified.
  • Right to Data Portability – You have the right to move, duplicate or transfer your data easily from one IT environment to another in a safe and secure way.
  • Right to Object – You have the right to object to profiling and direct marketing
  • You also have rights in relation to automated decision making.

You also have the right to lodge a complaint with the UK’s supervisory body, The Information Commissioners Office www.ico.org.uk

Automated decision making

Martyn Carr Coaching LTD does not use automated decision making to process personal data.

Third party websites

Our website may contain links to other websites. This privacy policy only applies to Martyn Carr Coaching, so if you follow a link to another website, you should read that organisation’s own privacy policy.

Changes to our privacy policy

We keep our privacy policy under review and we will place any updates on our website. This privacy policy was last updated in September 2018

How to contact us

You can write to us at this address:

Martyn Carr Coaching LTD

64, Jane’s Lane
Burgess Hill
RH15 0QR

You can telephone us on this number:

+44 (0)7740 638414

You can email us by using this link:

hello@martyncarrcoaching.co.uk

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